Answer:
The Fair Credit Reporting Act does not require written permission to access a credit report. Your loan policy may and you wouldn't want to violate that either, but it isn't an FCRA violation.
I suggest telephone applications be dated, time-stamped and denote who took the application and that it was by phone. This provides you an audit trail.
Reg. B revisions which became mandatory April 15, 2004, also require that you have a solid procedure to denote "joint intent" on joint applications. If you revise your telephone procedures, be sure to include this.
First published on BankersOnline.com 10/4/04